LAST UPDATED: September 14, 2020
1. What types of information do we access?
DynamiCard utilizes plastic postcards and data analytics to assist its clients with direct mail marketing. As part of its Service, DynamiCard accesses the following “information” (meaning personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household). Please note that DynamiCard accesses and uses information on behalf of its third-party clients, and most personally identifying information that is accessed about you has already been made public.
- Information You Provide. We may access information from you when you voluntarily provide it to us over the Service, though this is not the primary information we access.
- Content You Make Public. We may access information that you make public, such as when you post a review or a comment on a good or service.
- Transaction and Payment Information. We may access information when you order a product or service through or using the Service, such as details of redeeming a coupon.
- Device/Internet Connection Information. If you use certain parts of the Service, we may automatically gather information made available by your web browser, internet service provider, and device, depending on your settings for each. For example, we may gather your IP address, information about the operating system or type of device you use, the device ID associated with your device, and the date and time you access the Service.
- Internet Activity Information. If you use certain parts of the Service, we may gather information about your browsing history, search history, and information regarding your interaction with a particular website, application, or advertisement, including the Service.
- Geolocation Information. We may gather information about where you are located, both generally and at the time that you access certain parts of the Service.
- Protected Class Information. We may access protected class information, such as race, ethnicity, nationality, gender, age, marital or family status, and sexual orientation.
- Education and Employment Information. We may access information about your educational background, employment, employment history, or salary.
- Other Information. From time to time, we may access other information from you, such as if you contact customer service or voluntarily subscribe to a promotion.
- Inference Information. We may create new information about you by drawing inferences from the information identified in the categories listed above, such as to create a profile about you reflecting your preferences and trends.
2. How and when do we access information?
DynamiCard gathers the information outlined in Section 1 in these ways:
- Through Data Compliers. DynamiCard rents information from third-party data compilers for direct mail campaigns. These third-parties are subject to their own privacy policies and practices and may be registered in your state as a data broker, if applicable. As outlined below, your information obtained from data compilers is used for sending you direct mail, such as plastic postcard coupons, that may be of interest to you.
- Through Client Campaigns. DynamiCard clients may provide your information to DynamiCard for a direct mailing campaign on behalf of the respective client that provided your information. As outlined below, your information is used for the client that provided your information, such as if you purchased a good or service from a retailer, and that retailer client uses DynamiCard’s Service to provide additional offers to you. In these cases, DynamiCard is solely acting as a service provider for the respective client.
- Through Data Analytics. As part of the Service, DynamiCard may access your information regarding your transactions with DynamiCard’s clients through an automated process after you scan or redeem a plastic coupon card at the client establishment. For example, if you redeem a plastic coupon card at a restaurant, DynamiCard may access information about your restaurant transaction.
- Information You Provide. DynamiCard may access any information that you provide on or using the Service, such as if you enter information on a form, communicate with us (e.g., by email or text)or post a review and mention us, and any information that you make public.
3. How do we use your information?
DynamiCard uses the information outlined in Section 1 for the following purposes:
Business Purposes. The following are our Business Purposes (i.e., uses reasonably necessary and proportionate to achieve an operational purpose of DynamiCard):
- For Security. We may use information to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify bad actors.
- To Provide the Service.
- For Direct Mail. DynamiCard uses information obtained from data compilers, in particular your name and address, to send you direct mail that may be of interest to you, such as plastic postcard coupons, on behalf of its third-party clients. Please note that DynamiCard is not responsible for advertising content.
- For Client Campaigns. DynamiCard uses information obtained from a specific client for a marketing campaign on behalf of that respective client. In such cases, DynamiCard is solely acting as a service provider for the respective client.
- For Data Analytics. DynamiCard uses information about your transaction, such as if you redeem a coupon card, for data analytics. DynamiCard may combine this information with other available information for aggregate data analytics.
- To Improve the Service. We may use information to help improve our Service.
- To Personalize Your User Experience. We may use information, such as any information gathered through Cookies, to personalize and streamline your experience.
- To Communicate with You. We may use information to personalize communication with you, to respond to your requests, and to notify you of legal updates.
- To Create Deidentified Aggregate Information. Your information may be combined with that of other users to be accessed as “aggregate information” (i.e., statistical information about all users or a subset thereof). Aggregate information is pseudonymized and deidentified and cannot be used to identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. In turn, aggregate information may be used for our Business and Commercial Purposes.
Commercial Purposes. The following are our Commercial Purposes (i.e., uses intended to advance business interests, such as by inducing you to make a purchase):
- To Build a Profile. DynamiCard may create new information about you by drawing inferences from the information identified in the categories listed in Section 1, such as to create a profile about you reflecting your preferences and trends.
- To Advertise to Others. We may share your public content, such as if you post a positive review about us, to advertise our Service, such as on our website or social media page.
4. How do we share your information?
DynamiCard shares the information outlined in Section 1 with third parties in the following ways.
Business Purposes. The following are our Business Purposes for sharing information:
|Third Parties||Business Purpose||Information Shared|
|Service Providers. These third parties provide services to DynamiCard that allow DynamiCard to operate and provide the Service, for example, payment processors and web developers.||For Security; to Provide and Improve the Service; to Personalize User Experience; and to Create Aggregate Information.||Information outlined in Section 1.|
|Clients Using Marketing Services. DynamiCard shares information with clients using DynamiCard’s marketing services.||To Provide the Service.||Information outlined in Section 1 only if you scan a coupon at the respective client establishment.|
|Clients Using Analytics Services. DynamiCard shares information with clients using DynamiCard’s analytics services.||To Provide the Service.||Information outlined in Section 1 only if you scan a coupon at the respective client establishment (as well as aggregate information, which is not personal or identifiable “information”).|
|Government Officials and Private Parties Pursuant to Valid Legal Process. We may disclose information in response to subpoenas, court orders, and other legal processes. In rare circumstances, we may disclose information when we believe it is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.||
To Comply with Legal Obligations; and to Prevent Fraud, Harm, or Illegal Conduct.
|Information outlined in Section 1.|
Commercial Purposes. The following are our Commercial Purposes for sharing information:
|Third Parties||Commercial Purpose||Information Shared|
|Advertising Partners. We may disclose your information as needed to third-party advertising partners in order to provide the Service..||To Advertise to You||Information outlined in Section 1.|
Certain practices may be considered a “sale” under California privacy legislation.
RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION
You have the right, at any time, to direct DynamiCard not to sell your information. You may do so by filling out the Do Not Sell My Personal Information form on our website. You may also make a request by contacting us as outlined in Section 13.
5. How do we protect your information?
DynamiCard employs technical, administrative, and physical security measures that are designed to protect against the loss, misuse, and alteration of the information under our control. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot promise, and you should not expect, that your personal and commercial information will always remain secure. The safety and security of your information also depends on you. Notify us as soon as possible if you believe your security has been breached.
6. How long do we keep your information?
7. Do we transfer your information to a different country?
If you are visiting the Service from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and maintained in our web servers and internal systems located within the United States. By using the Service, you authorize and specifically consent to the transfer of personal information to the United States and its storage and use as specified herein.
8. What are your rights when it comes to accessing, correcting, or deleting your information, and how can you exercise them?
Under certain privacy legislation, which may apply to you, you may request to correct, amend, access, or delete information. These requests can be made by contacting us through our Privacy Request Form or by emailing [email protected]. You may also make any of the requests outlined below by contacting us as outlined in Section 13. We will not discriminate against you for making a privacy request or asserting privacy rights. To protect your privacy and security, we may take reasonable steps to help verify your identity before granting your request. We may also take steps to verify any authorized agent making a request. If such privacy legislation applies to you:
- Access and Correction
You have the right to request access to or correction of your information.
- Right to Request Disclosure
You have the right to request that we disclose the following to you: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; and the specific pieces of personal information we have collected about you.
- Right to Request Deletion
You have the right to request that we delete any personal information about you.
- California Shine the Light Disclosure
Under California’s “Shine the Light” law, California residents who provide personal information to the Service may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
- RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION
You have the right, at any time, to direct DynamiCard not to sell your information. You may do so by filling out the Do Not Sell My Personal Information form on our website.
9. How do we protect the privacy of children?
DynamiCard will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to third parties. We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).
10. How can you opt-out from marketing communications?
The Service may include sending you marketing communications on behalf of DynamiCard’s clients via mail, email, and, if you provide requisite consent, text messages. You can unsubscribe to marketing communications by following the unsubscribe instructions contained in each communication or by contacting us as outlined in Section 13. Please note that, even if you unsubscribe from advertising messages, we will still send you any necessary, non-promotional communications, and you may need to opt-out with third parties to cease communications.
11. Do we respond to Do Not Track (DNT) signals?
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked. We do not currently respond to DNT requests.
13. How can you contact us?
The Service contains a contact form, which can be used for electronic contact. If you use this option, the data entered will be transmitted to us and stored as part of your information. You can also contact us via email at [email protected]. In any case, your communication may be stored and, if needed, may be relayed to third party parties for the purpose of processing any request by you in the communication.